A customer deposits cash in the amount of $8,000 after the 2:00 cutoff time and another cash deposit the next day in the amount of $8,000 prompting a CTR. The teller requests ID information to complete a CTR and the customer ask why you have to complete a CTr. So the teller gives the customer the "Facts You Should Know" pamphlet. The customer says to give him the money back and he will come back next week. Would you say that that is a confession/admission to structuring?

First of all, I wouldn't return the money back over the counter. I would explain that the transaction cannot be changed at that point. And, yes, that is most assuredly a confession (not that you needed one).

I would give back money and file a SAR.

Why would you not give the money back?

You can give the money back but you still have to file the CTR. You can't 'undo' those transactions.

I would definitely file the SAR.

Thanks for the replies! So a CTR & a SAR and check yes on the SAR that there was an admission/confession.

Let's not leap at the CTR. If your teller agreed to hand back the second bundle of cash so that the deposit wasn't made, there's no CTR to be filed. But a SAR? Yes.

I would agree. File the SAR, if the customer was given their money back, you wouldn't file the CTR because the transaction was cancelled.

Sorry - I misread the initial information. I thought it was later that he requested the funds back, not at the time of deposit.

OK Thanks for all of the replies!!!

i would not check the admission/confession block on the SAR unless the person said I confess I'm structuring transactions. I would describe what happened in the narrative. It's not a big leap to know that someone structured a trasaction when they ask for the cash back and tell you that they'll deposit it next week.

I was always trained you "NEVER check the confession box" unless in a case like nemsi stated above. I've always wondered if this is common practice amongst other banks?

Has anyone ever checked the box? and if so, what were the circumstances?

Yes, when customer acknowledged that he/she had knowledge of the CTR and structured cash transactions to avoid having a CTR completed by the bank.

Also had some internal written confessions that prompted the box being checked.

We always check the box when a customer makes a statement that he/she was trying to avoid a CTR.

Unless the customer actually states they are structuring you should not check the cofesssion box. Instead, write in the narrative what the customer stated to the teller and include the teller's name. This is what our IRS-CID SAR coordinator advises.